I agree it's different in many respects, but to state the obvious, DD may not be based on actual income either, the tax is due even when you haven't realised a gain. From that perspective, DD can also be said to be hypothetical. For obvious reasons the amount of tax owed will be much closer to reality that than some of the examples given from the Dutch wealth tax, but the basic idea that you can be taxed on a gain you haven't actually made I think is interesting in the context of this judgement.However, it's very different from our deemed disposal.
It's based on actual income and not hypothetical income.
But someone will probably challenge it.
Brendan
I agree it's different in many respects, but to state the obvious, DD may not be based on actual income either, the tax is due even when you haven't realised a gain. From that perspective, DD can also be said to be hypothetical. For obvious reasons the amount of tax owed will be much closer to reality that than some of the examples given from the Dutch wealth tax, but the basic idea that you can be taxed on a gain you haven't actually made I think is interesting in the context of this judgement.
Thanks Itchy, I hadn't appreciated how many deemed taxes were actually in operation!DD would difficult if the underlying assets were non-marketable I suppose, but the you would be due a refund on realisation, if you overpaid tax, so quite different to NL I think.
If you conduct a transaction that's not deemed to have occurred at the market rate, e.g. a connected party asset sale, Revenue will deem the transaction to have occurred at market rate, whatever that is? Or if you import a car they will tax you on an 'open market selling price' of the vehicle, rather than the market price you paid!
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